By: Rachel Meyer, Ohio River Valley Field Organizer, Moms Clean Air Force
Date: March 10, 2026
About: EPA Docket ID No. EPA-HQ-OLEM-2025-0313
To: Environmental Protection Agency
My name is Rachel Meyer, and I am the Ohio River Valley Field Organizer for Moms Clean Air Force. We urge EPA to maintain the requirements of the Risk Management Program in order to protect the health and safety of families and communities near RMP facilities.
My family lives near Shell Polymers Monaca, one of the largest petrochemical complexes in North America. Since I first testified for strengthening the proposed Safer Communities by Chemical Accident Prevention Rule on September 28, 2022, the facility has had at least 80 malfunctions, including four high priority events last year. On June 4, 2025, one of these malfunctions resulted in a fire and chemical release of benzene and 1, 3 butadiene which is being investigated by the National Chemical Safety Board. I want to know that robust, potentially lifesaving, health and safety requirements are required and in place to help protect workers, my family, and all the families living close to this, and all other, high-risk facilities.
The EPA estimates that approximately 150 serious accidents occur at regulated industrial facilities every year, resulting in deaths, serious injuries, evacuations, and other related physical and mental health harms. The petrochemical industry alone risks the health and safety of its workers and those in nearby communities by averaging one incident such as a spill, fire, or explosion every three days in the U.S.
In my job as an organizer, I am sometimes contacted by members of communities who are worried about their health and safety due to proposed or existing facilities. One such facility is the Keystate Natural Gas Synthesis plant proposed in Karthaus, Pennsylvania. Residents there living next to the plant or in the village half a mile from it are concerned because the facility will be producing ammonia. Ammonia is a flammable gas that can cause severe irritation and chemical burns to the eyes, skin, and respiratory tract, and in extreme cases, can be fatal. It is one of the dangerous chemicals that triggers the RMP requirements. The families and community members of Karthaus will need the strongest possible protections if this facility moves forward.
Chemical disasters are a real threat to the nearly 200 million community members in our country who live near Risk Management Program facilities, over half the U.S. population. Over one in every three school children in the U.S. attends a school within the vulnerability zone of a hazardous chemical or petrochemical facility. Half of these children are in schools located in more than one chemical vulnerability zone.
I urge the EPA to maintain a strong, comprehensive, and enforceable Safer Communities by Chemical Accident Prevention rule keeping solutions such as for facilities to assess and plan for natural hazards and power loss, put safer technologies and measures in place, provide information in multiple languages for affected communities, enact vital employee participation measures ensuring that workers inside a chemical facility can help prevent or stop an unfolding emergency, and require independent compliance auditing after harmful incidents occur. The health and safety of families and communities living in the dangerous zones near Risk Management Program facilities depends on it.
Thank you for the opportunity to comment.